Lessons from Implementing the 1990 CAA Amendments
E. Donald Elliott
Yale Law School
June 1, 2010
Environmental Law Reporter, Vol. 40, No. 10592, 2010
Yale Law & Economics Research Paper No. 419
Lessons learned from implementing the Clean Air Act Amendments of 1990 by the General Counsel of EPA during passage and first year of implementation. Elliott argues that first main lessons to be learned from EPA's successful implementation of the 1990 Amendments were:
1. Establish and communicate clear priorities; 2. Develop a specific plan, with clear responsibilities and deadlines; 3. Early collaboration and cost-effective implementation; 4. Let others take the credit and win over the opposition; 5. Learn the lessons of history and keep it simple, stupid.
The main mistake that the author describes is being so focused on meeting statutory deadlines that matters that were important from a policy perspective (such as opt-in rules for trading) fell through the cracks if they had no mandatory deadline.
Number of Pages in PDF File: 6
Keywords: Clean Air Act, implementationAccepted Paper Series
Date posted: November 17, 2010 ; Last revised: December 20, 2010
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